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Our Compliance with #4040

By Dan Hadaway | Monday, February 26, 2018 - Leave a Comment

Dan’s decided to declare “in compliance” on a CAT Statement, and wants your opinion!


Another one of those Dan’s New Leaf Posts, meant to inspire thought about IT Governance . . . .


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How would you like to experience a little excerpt from an infotex risk assessment?  (Yes, we had to run this by our Information Security Officer for clearance.)

For our readers who are familiar with the Cybersecurity Assessment Tool, we have our own flavor called the CAT MAIT which, among other things, numbers each “statement” at the statement, and not component, level, so we can refer to it without reading the whole darn statement.  So hidden in the fourth domain (Third Party Management), at the Innovative Level, is #4040, which reads like this:

“The institution promotes a sector-wide effort to influence contractual requirements for critical third parties to the industry.”

We decided this year to declare this “In Compliance.”  And here is our notation in the “comments” column:

02/05/18:  We decided to declare this “in compliance” because we do this, not only through our work with the IBA and our support of the IBA and OBL, but through our blog when we can, and when we talk to the FFIEC examiners.  But we also do this every single time we audit a bank.  Especially when there are findings that are caused by third parties, and when we audit vendor management programs.  Our primary goals for change:

1) Let the TSP Examination Report be the due diligence for smaller community based banks (banks under a billion should not have to do due diligence on their core processor when the FFIEC is camping out there year round!!!)

2) Create standard contract terms that all vendors can point to, and that auditors assert are being enforced.  It would be great if all we had to do was state, in our contract, “infotex agrees to maintain compliance with the current copy of Standard Information Security Control Terms published at ffiec.gov” or something like that!!

So how about some feedback?  Here’s your chance to audit the auditors!

Do you think we are enforcing this control, as declared?


Original article by Dan Hadaway CRISC CISA CISM. Founder and Managing Partner, infotex

“Dan’s New Leaf” is a “fun blog to inspire thought in the area of IT Governance.”


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